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Staringstraat 28 H, 1054VR Amsterdam,

The Netherlands

> COOKIE POLICY

> PRIVACY POLICY


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PRIVACY POLICY.

© 2021 VL Project Manager

Types of Data collected

Among the types of Personal Data that this site collects, by itself or through third parties, there are: email address, first name, last name, Cookies, Usage Data, telephone number, profession, province, country, ZIP code, date of birth, city, address, company name, website, various types of Data, VAT number, Tax Code, sector of activity, User ID, geographical location, image,  Data communicated during the use of the service and unique identifiers of devices for advertising.


Other Personal Data collected may be indicated in other sections of this privacy policy or through informative texts displayed at the same time as the collection of the Data.
Full details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the collection of the data.
Personal Data may be entered voluntarily by the User, or collected automatically during the use of this website.
Unless otherwise specified, all Data requested by this website are mandatory. If the User refuses to communicate them, it may be impossible for this Application to provide the Service. 
In cases where this website indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation.
Users who have doubts about which Data are mandatory, are encouraged to contact the Owner.
Any use of Cookies - or other tracking tools - by this website or by the owners of third-party services used by this website, unless otherwise specified, has the purpose of identifying the User and recording their preferences for purposes strictly related to the provision of the service requested by the User.
Failure by the User to provide some Personal Data may prevent this website from providing its services.
The User assumes responsibility for the Personal Data of third parties published or shared through this Application and guarantees to have the right to communicate or disseminate them, freeing the Owner from any liability to third parties.

 

Methods and place of processing of collected data
Processing methods

The Data Controller processes the Personal Data of Users by adopting the appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
The processing is carried out using IT and / or telematic tools, with organizational methods and with logic strictly related to the purposes indicated.
In addition to the Data Controller, in some cases, the Data may be accessed by categories of persons in charge involved in the organization of the site (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller.

 

Legal basis of the processing
The Data Controller processes Personal Data relating to the User if one of the following conditions exists:
- the User has given consent for one or more specific purposes; Note: in some jurisdictions the Owner may be authorized to process Personal Data without the User's consent or another of the legal bases specified below, until the User objects ("opt-out") to such processing. 
- the processing is necessary for the execution of a contract with the User and / or the execution of pre-contractual measures;
- the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
- the processing is necessary for the performance of a task carried out in the public interest or for the exercise of public authority vested in the Data Controller;
- the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.

 However, it is always possible to request the Data Controller to clarify the concrete legal basis of each treatment and in particular to specify whether the processing is based on the law, provided for by a contract or necessary to conclude a contract.


Place
The Data are processed at the operational headquarters of the Data Controller and in any other place where the parties involved in the processing are located. For more information, contact the Data Controller.
The User's Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of processing, the User can refer to the section on the details on the processing of Personal Data.
The User has the right to obtain information regarding the legal basis of the transfer of Data outside the European Union or to an international organization of public international law or consisting of two or more countries, such as the UN, as well as about the security measures taken by the Data Controller to protect the Data


Retention period

Data are processed and stored for the time required by the purposes for which they were collected.
Therefore:
Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed.
Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner.

When the processing is based on the User's consent, the Data Controller may keep the Personal Data longer until such consent is revoked. In addition, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or by order of an authority
At the end of the retention period, the Personal Data will be deleted. Therefore, at the end of this term the right of access, cancellation, rectification and the right to data portability can no longer be exercised.


Purposes of the Processing of Collected Data

Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Access to accounts on third-party services, Contacting the User, Managing contacts and sending messages, Managing payments, Managing support and contact requests, Hosting and backend infrastructure, Content commenting, Social features, Tag management, Analytics, Interaction with external social networks and platforms,
Heat mapping and session recording,
Interaction with live chat platforms,
Interaction with support and feedback platforms, Location-based interactions, Permissions to access Personal Data on the User's device, SPAM protection, Advertising, Registration and authentication, Remarketing and behavioral targeting, Content and functionality performance testing (A/B testing), Transfer of Data outside the EU and Display of content from external platforms.
To obtain further detailed information on the purposes of the processing and on the Personal Data concretely relevant for each purpose, the User can refer to the relevant sections of this document.

 

Facebook permissions required by this site
This Application may request certain Facebook permissions that allow it to perform actions with the User's Facebook account and to collect information, including Personal Data, from it. This service allows this website to connect with the User's account on the social network Facebook, provided by Facebook Inc.
For more information on the following permissions, please refer to the Facebook permissions documentation and the Facebook privacy policy.

 

Basic information
The basic information of the User registered on Facebook which normally includes the following Data: id, name, image, gender and language of localization and, in some cases, the "Friends" of Facebook. If you have made additional Data publicly available, it will be available.


Details on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:

Access to accounts on third-party services
This type of service allows this Application to take Data from your accounts on third-party services and perform actions with them.
These services are not activated automatically, but require the express authorization of the User.

Content commentary
The comment services allow Users to formulate and make public their own comments regarding the content of this website.
Users, depending on the settings decided by the Owner, can also leave the comment anonymously. If among the Personal Data released by the User there is the email, this could be used to send notifications of comments regarding the same content. Users are responsible for the content of their comments.
In the event that a comment service provided by third parties is installed, it is possible that, even if the Users do not use the comment service, the same collects traffic data relating to the pages where the comment service is installed.


Contacting the User
Mailing list or newsletter

By registering to the mailing list or newsletter, the User's email address is automatically included in a list of contacts to which email messages containing information, including commercial and promotional information, relating to this Application may be transmitted. The User's email address may also be added to this list as a result of registering with this Application or after making a purchase.

Personal Data collected: ZIP code, city, surname, Cookie, date of birth, Usage data, email address, country, name, telephone number, profession, province, company name and website.

Contact by phone 
Users who have provided their telephone number may be contacted for commercial or promotional purposes related to this Application, as well as to satisfy support requests.
Personal Data collected: telephone number.

 

Contact form
By filling in the contact form with their Data, the User consents to their use to respond to requests for information, quotes, or any other nature indicated by the form's header.
Personal Data collected: ZIP code, city, Tax Code, surname, date of birth, email address, User ID, address, country, name, telephone number, VAT number, profession, province, company name, gender, sector of activity, website and various types of Data.

 

Managing contacts and sending messages
This type of service allows you to manage a database of email contacts, telephone contacts or contacts of any other type, used to communicate with the User.
These services may also allow us to collect data relating to the date and time of display of the messages by the User, as well as the User's interaction with them, such as information on clicks on the links inserted in the messages.

Mailgun (Mailgun, Inc.)

Mailgun is an address management and email sending service provided by Mailgun, Inc.
Personal Data collected: surname, Cookie, date of birth, Usage data, email address, country, name, telephone number, profession, gender and various types of Data.
Place of processing: United States – Privacy Policy.

 

Google Cloud Storage (Google Ireland Limited)

Google Cloud Storage is a hosting service provided by Google Ireland Limited.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy .


Interaction with external social networks and platforms
This type of service allows you to interact with social networks, or other external platforms, directly from the pages of this Application.
The interactions and information acquired by this Application are in any case subject to the User's privacy settings relating to each social network.

Like button and Facebook social widgets (Facebook, Inc.)

The "Like" button and social widgets of Facebook are services of interaction with the social network Facebook, provided by Facebook, Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy .

 

Location-based interactions
Non-continuous geolocation (this website)

This website may collect, use and share Data relating to the User's geographical location, in order to provide location-based services.
Most browsers and devices provide tools by default to deny geo-tracking. If the User has expressly authorized this possibility, this Application may receive information on its actual geographical location.
The geographical location of the User takes place in a non-continuous manner, upon specific request of the User or when the User does not indicate in the appropriate field the place where he is located and allows the application to automatically detect the location.
Personal Data collected: geographical location.

 

SPAM protection
This type of service analyzes the traffic of this Application, potentially containing Personal Data of Users, in order to filter it from parts of traffic, messages and content recognized as SPAM.


Google reCAPTCHA (Google Ireland Limited)

Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.
The use of the reCAPTCHA system is subject to Google's privacy policy and terms of use.
Personal Data collected: Cookies and Usage Data.
Place of processing: Ireland – Privacy Policy.

 

Registration and authentication

By registering or authenticating, the User allows the Application to identify him and give him access to dedicated services.
Depending on the following, registration and authentication services may be provided with the help of third parties. If this happens, this application will be able to access some Data stored by the third-party service used for registration or identification.

 

Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of the User's behavior.

Google Analytics is a web analytics service provided by Google Ireland Limited ("Google"). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google.

Google may use Personal Data to contextualize and personalize the ads of its advertising network.
Personal Data collected: Cookies and Usage Data.
Place of processing: Ireland – Privacy Policy - Opt Out


Google Analytics con IP anonimizzato (Google Ireland Limited)

Google Analytics is a web analytics service provided by Google Ireland Limited ("Google"). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google.
Google may use Personal Data to contextualize and personalize the ads of its advertising network.
This integration of Google Analytics anonymizes your IP address. Anonymization works by shortening the IP address of Users within the borders of member states of the European Union or in other countries party to the Agreement on the European Economic Area. Only in exceptional cases will the IP address be sent to Google's servers and shortened within the United States.
Personal Data collected: Cookies and Usage Data.
Place of processing: Ireland – Privacy Policy - Opt Out

 

Transfer of Data outside the EU
The Data Controller may transfer Personal Data collected within the EU to third countries (i.e., all countries outside the EU) only in accordance with a specific legal basis. Therefore, such data transfers are carried out according to one of the legal bases described below
The User may request information from the Owner regarding the applicable legal basis concretely applicable to each individual service.

 

Transfer to third countries on the basis of standard contractual clauses
When this is the legal basis, the transfer of Personal Data from the EU to third countries takes place on the basis of standard personal data protection clauses adopted by the European Commission.
In such cases, the recipients of the Data have agreed to process the Personal Data in accordance with the levels of protection provided for by the legislation. Users can request further information by contacting the Data Controller at the details indicated in this document.

Transfer to third countries based on consent

When this is the legal basis, the transfer of Personal Data from the EU to third countries takes place only when the User has expressly consented to such transfer after being informed of the risks due to the absence of an adequacy decision and the appropriate safeguards adopted
In such cases, the Owner informs the Users and collects their consent through this Application.
Personal Data collected: various types of Data.

Transfer of Data to countries that guarantee European standards 

When this is the legal basis, the transfer of Personal Data from the EU to third countries takes place on the basis of an adequacy decision adopted by the European Commission. The European Commission adopts adequacy decisions with reference to individual third countries that it considers to guarantee a level of protection of Personal Data comparable to that provided for by European legislation on the protection of Personal Data.


Viewing content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Application and to interact with them.
In the event that a service of this type is installed, it is possible that, even if the Users do not use the service, the same collects traffic data relating to the pages in which it is installed.

Google Fonts (Google Ireland Limited)

Google Fonts is a font style display service operated by Google Ireland Limited that allows this Application to integrate such content within its pages.
Personal Data collected: Usage data and various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.

Analysis of User Data and forecasts ("profiling")

The Data Controller may process the usage data collected through this Application to create or update user profiles. This type of processing allows the Data Controller to evaluate the choices, preferences and behavior of the User for the purposes specified in the respective sections of this document.


Personal Data collected through sources other than the User

The Owner of this Application may have legitimately collected Personal Data relating to the User without his involvement, drawing on sources provided by third parties, in accordance with the legal bases described in the section on the legal bases of the processing.


Sale of goods and services online

The Personal Data collected is used for the provision of services to the User or for the sale of products, including payment and possible delivery. The Personal Data collected to complete the payment may be those relating to the credit card, the current account used for the transfer or other payment instruments provided. The Payment Data collected by this website depends on the payment system used.

 

User Rights
Users can exercise certain rights with reference to the Data processed by the Data Controller.
In particular, the User has the right to:
-revoke the consent at any time. The User can revoke the consent to the processing of their Perso-nal Data previously expressed.
-oppose the processing of their Data. The User can object to the processing of their Data when it takes place on a legal basis other than consent. 
Further details on the right to object can be found in the section below.
-access your Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed.
-verify and request rectification. The User can verify the correctness of their Data and request its updating or correction.
-obtain the limitation of the treatment. 

Information not contained in this policy
More information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact information.

Exercise of rights by Users
The subjects to whom the Personal Data refer have the right at any time to obtain confirmation of the existence or otherwise of the same from the Data Controller, to know its content and origin, to request a copy of all the data processed, to verify its accuracy or request the integration, cancella-tion of the data processed.

 

Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to Users on this page. Please therefore consult this page often, taking as a reference the da-te of last modification indicated at the bottom. In the event of non-acceptance of the changes ma-de to this privacy policy, the User is required to cease using this website and may request the Data Controller to remove their Personal Data. Unless otherwise specified, the previous privacy policy will continue to apply to Personal Data collected up to that time.

Cookie
Small portion of data stored within the User's device.

 

Legal references
This privacy statement is drawn up on the basis of multiple legislative systems, including Articles. 13 and 14 of Regulation (EU) 2016/679.

Contacts
If you have any questions regarding this Privacy Policy, please contact us at info@spgcfb.org

Date of last revision: 10/10/2022